TCH submitted a comment letter in response to Nacha’s proposal regarding account information improvements. The proposal addressed several issues: Pre-Notes; Micro-entries; NOCs; and Rules Enforcement. In particular, the proposal would, among other things:
- establish new requirements for RDFIs to respond to all Pre-Notes they receive and for ODFIs to code entries with additional descriptive information;
- define and create a Nacha rules framework, including standardized formatting, for Micro-Entries (entries of less than $1 used for account validation purposes);
- require ODFIs to provide information from a NOC to its Originator within one banking-day; and
- strengthen Nacha rules enforcement provisions where an ODFI’s Originator does not use corrected information from a NOC
There was not a consensus among The Clearing House’s member banks on several aspects of the proposal. The letter, therefore, reflects those differing opinions. For example, some member banks recognize how the changes to Pre-Notes would enhance the overall quality of live transactions for Originators and RDFIs, while others do not believe the costs associated with RDFIs responding to every Pre-Note within one banking-day are justified by the potential incremental benefits. Similarly, some member banks recognize a benefit in formalizing the existing use of micro-entry validation and thereby highlighting the purpose of a Micro-Entry, while others do not believe that the lack of standardized formatting for Micro-Entries is a problem that needs to be addressed and that the proposed change may create an unnecessary burden on ODFIs to police their Originator’s formatting practices.
To read the full comment letter click here.